Schedule 1 – Definitions
      Effective from Feb 07 2023 - Feb 06 2023
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| Term | Definition | |||||||||||
| “AML/CFT” | has the meaning ascribed to it in the Regulations. | |||||||||||
| “Anonymity-Enhanced Cryptocurrencies” | has the meaning ascribed to it in the Regulations. | |||||||||||
| “Anonymity-Enhanced Transactions” | means transactions denominated in Virtual Assets which are not Anonymity-Enhanced Cryptocurrencies, but which prevent the tracing of transactions or record of ownership. | |||||||||||
| “BCDR Plan” | means the Business Continuity and Disaster Recovery Plan of a VASP. | |||||||||||
| “Board” | has the meaning ascribed to it in the Company Rulebook. | |||||||||||
| “Capital and Prudential Requirements” | has the meaning ascribed to it in the Company Rulebook. | |||||||||||
| “CDD” | means client due diligence, including but not limited to due diligence on the clientele of a VASP’s client. | |||||||||||
| “Client Account” | has the meaning ascribed to it in Part IV of this Compliance and Risk Management Rulebook. | |||||||||||
| “Client Money” | has the meaning ascribed to it in Part IV of this Compliance and Risk Management Rulebook. | |||||||||||
| “Client VA” | has the meaning ascribed to it in Part V of this Compliance and Risk Management Rulebook. | |||||||||||
| “CMS” | means the compliance management system of a VASP. | |||||||||||
| “Compliance Officer” or “CO” | has the meaning ascribed to it in Part I of this Compliance and Risk Management Rulebook. | |||||||||||
| “Company Rulebook” | means the Company Rulebook issued by VARA pursuant to the Regulations, as may be amended from time to time. | |||||||||||
| “Compliance and Risk Management Rulebook” | means this Compliance and Risk Management Rulebook issued by VARA pursuant to the Regulations, as may be amended from time to time. | |||||||||||
| “Controlling Entity” | has the meaning ascribed to it in the Company Rulebook. | |||||||||||
| “Decentralised Autonomous Organisation” or “DAO” | has the meaning ascribed to it in the Company Rulebook. | |||||||||||
| “Directive” | has the meaning ascribed to it in the Regulations. | |||||||||||
| “Dubai VA Law” | means Law No. [4] of 2022 Regulating Virtual Assets in the Emirate of Dubai, as may be amended from time to time. | |||||||||||
| “Emirate” | means all zones across the Emirate of Dubai, including Special Development Zones and Free Zones but excluding the Dubai International Financial Centre. | |||||||||||
| “Entity” | means any legal entity or individual. | |||||||||||
| “EOCN” | means the UAE Executive Office for Control & Non-Proliferation. | |||||||||||
| “FATCA” | means the United States Foreign Account Tax Compliance Act. | |||||||||||
| “FATF” | means the Financial Action Task Force. | |||||||||||
| “Federal AML-CFT Laws” | has the meaning ascribed to it in the Regulations. | |||||||||||
| “Fit and Proper Person” | means an individual who complies with all fit and proper requirements in the Company Rulebook. | |||||||||||
| “GoAML” | means the electronic platform through which Suspicious Transaction reports can be submitted to the UAE FIU. | |||||||||||
| “Group” | has the meaning ascribed to it in the Company Rulebook. | |||||||||||
| “Guidance” | has the meaning ascribed to it in the Regulations. | |||||||||||
| “Inside Information” | has the meaning ascribed to it in the Regulations. | |||||||||||
| “Insolvency Proceedings” | has the meaning ascribed to it in the Regulations. | |||||||||||
| “Licence” | has the meaning ascribed to it in the Regulations. | |||||||||||
| “Licensed” | means having a valid Licence. | |||||||||||
| “Market Conduct Rulebook” | means the Market Conduct Rulebook issued by VARA pursuant to the Regulations, as may be amended from time to time. | |||||||||||
| “Money Laundering Reporting Officer” or “MLRO” | has the meaning ascribed to it in Rule III.A.1 of this Compliance and Risk Management Rulebook. | |||||||||||
| “Outsourcing” | has the meaning ascribed to it in the Company Rulebook. | |||||||||||
| “Politically Exposed Person” or “PEP” | has the meaning ascribed to it in the Company Rulebook. | |||||||||||
| “PDPL” | means the Federal Decree-Law No. [45] of 2021 on the Protection of Personal Data. | |||||||||||
| “Personal Data” | has the meaning ascribed to it in the PDPL. | |||||||||||
| “Regulations” | means the Virtual Assets and Related Activities Regulations 2023, as may be amended from time to time. | |||||||||||
| “Related Parties” | has the meaning ascribed to it in the Company Rulebook. | |||||||||||
| “Reserve Assets” | has the meaning ascribed to it in the Company Rulebook. | |||||||||||
| “Responsible Individuals” | has the meaning ascribed to it in the Company Rulebook. | |||||||||||
| “Rule” | has the meaning ascribed to it in the Regulations. | |||||||||||
| “Rulebook” | has the meaning ascribed to it in the Regulations. | |||||||||||
| “Senior Management” | has the meaning ascribed to it in the Company Rulebook. | |||||||||||
| “Staff” | has the meaning ascribed to it in the Company Rulebook. | |||||||||||
| “Suspicious Transaction” | 
			
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| “Technology and Information Rulebook” | means the Technology and Information Rulebook issued by VARA pursuant to the Regulations, as may be amended from time to time. | |||||||||||
| “Third-Party Bank” | has the meaning ascribed to it in Part IV of this Compliance and Risk Management Rulebook. | |||||||||||
| “Travel Rule” | has the meaning ascribed to it in FATF’s Updated Guidance for a Risk-Based Approach for Virtual Assets and Virtual Asset Service Providers [October 2021], as may be amended from time to time. | |||||||||||
| “UAE” | means the United Arab Emirates. | |||||||||||
| “UAE FIU” | means the UAE Financial Intelligence Unit. | |||||||||||
| “Ultimate Beneficial Owner” or “UBO” | has the meaning ascribed to it in the Company Rulebook. | |||||||||||
| “VA Activity” | means the activities listed in Schedule 1 of the Regulations, as may be amended from time to time. | |||||||||||
| “VA Wallet” | has the meaning ascribed to the term “Virtual Asset Wallet” in the Dubai VA Law. | |||||||||||
| “VARA” | means the Dubai Virtual Assets Regulatory Authority. | |||||||||||
| “VASP” | means an Entity Licensed by VARA to conduct VA Activity[ies] in the Emirate. | |||||||||||
| “Virtual Asset” or “VA” | has the meaning ascribed to it in the Dubai VA Law. | |||||||||||